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Background on F2F Home Health Provision

In the final rule, CMS extend the period of time in which the F2F encounter could occur to 90 days prior to, or 30 days after, the start of home health services. A physician must document that the physician or an applicable non-physician practitioner has had a F2F encounter with the patient and the date of that encounter. The physician must also document how the patient's clinical condition supports a homebound status and the need for skilled services. The documentation must be a separate and distinct section of, or an addendum to, the certification.

Home Health Face-to-Face Requirements and Therapy Mandates (September 2010)
Hospice Face-to-Face Requirements for Recertification (September 2010)

CMS Releases Q&A Document on Face-To-Face Encounters

The Center for Medicare and Medicaid Services (CMS) has been responding to questions raised by VNAA members and other providers about the new F2F requirements for home health and hospice. VNAA staff has compiled the questions that have been answered as of March 16, 2011, and will continue to update this site periodically as new questions and answers are provided. You can always access the most updated CMS Q&A on  

Q&A Document as of March 16, 2011
Q&A Document as of February 13, 2011

Face-to-Face Coalition Letter to Jonathan Blum (March 12 2011)

CMS Update to Hospice Medicare Manual including New Policy on F2F Encounters in
Exceptional Circumstances (March 2011)

CMS Update to the Home Health Medicare Benefit Policy Manual, Pub 100-02 Chapter 7 (February 2011)

Face-to-Face Encounter Requirements Webinar  

Elizabeth Hogue Webinar on new F2F requirements (February 2011)

Handout on Provider Liability for Abandonment
FAQs about Use of Medical Directors for F2F
Handout on Medical Directors and the Stark Rule  

VNAA Advocacy on Face-to-Face Requirements

CMS Letter to Key Congressional Staff (December 23, 2010)

American Medical Association (AMA) Letter to CMS (December 23, 2010)

VNAA Letter to CMS (December 11, 2010)

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